Policies
Responsible automation
Where we use automated systems, what they do, and what a person always decides.
We use software to measure, to score and to watch: to count the hours a bed is occupied, to estimate a hospital’s credit risk, and to monitor the equipment enrolled in Continuity Assurance. Because the equipment we finance is used to care for critically ill patients, we hold those systems to a higher standard than a lender usually would.
Our commitments
- A person decides. No automated system of ours makes a credit decision, changes the terms of an agreement, or acts on a hospital’s equipment without a person confirming it.
- No patient data. Our systems do not receive patient identifiers or clinical data. Bed-hour metering uses the weight a bed reports, not who is in it.
- We follow the Turing Registry’s guidance. The Turing Registry, the public register of autonomous systems run by Frothly, publishes guidance on which systems should be filed and what their operators owe the public. We assess every automated system we build against that guidance before it is used, and again each year.
- Reviewed every year. Each system is reviewed annually by our model risk committee, and its performance reported to the audit and risk committee of our board.
| System | What it does | Who decides | Registry assessment |
|---|---|---|---|
| Bed-hour metering | Counts occupied hours from bed scales for Utilization Pricing statements | Billing team reviews each statement; hospitals can query any hour | Measurement only; not an autonomous system |
| Hospital credit scorecard | Scores credit from statements, cost reports and payer mix | Credit officers and the credit committee | Decision support; not an autonomous system |
| Early-contact model | Flags accounts likely to fall behind, so that a relationship manager calls early | Relationship managers | Decision support; not an autonomous system |
| Continuity Operations queue | Monitors enrolled equipment and recommends next steps on accounts in arrears | The duty manager confirms every action | Decision support; not an autonomous system |
Assessments last reviewed October 2026. Where a system of ours would act on equipment used in patient care without a person’s confirmation, we would file it with the Turing Registry before using it.